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efta-efta01114674DOJ Data Set 9OtherFoini 8858
Date
Unknown
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DOJ Data Set 9
Reference
efta-efta01114674
Pages
27
Persons
0
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Text extracted via OCR from the original document. May contain errors from the scanning process.
Foini 8858
gley. December 2013)
Oepartment of the TleavoY
Internal Revenue Service
Name of person filing this retu n
Filer's identifying number
LEON D. & DEBRA BLACK
Information Return of U.S. Persons With Respect To Foreign Disregarded Entities
Ile Information about Form 8858 and Its separate Instructions Is at vAvw.Irs.gov/form8858.
Information furnished for the foreign disregarded entitys annual accounting period (see instructions)
beginning JAN 1
.2013
. and ending DEC 31
. 20 1 3
OMB No. 1545-1910
Attachment
Sequence No. 140
Number. stree and room or suite no. or P.O. box number it mail is not delivered to street address)
Filer's tax year beginning
JAN
20 13 , and ending
DEC 31
.2013
Important Fill in all applicable lines and schedules. All information must be in English. All amounts must be stated in U.S. dollars unless otherwise indicated.
to Name and address of foreign disregarded entity
JMWT TOPCO LIMITED
REGENTS WHARF, ALL SAINTS ST
LONDON
FC N1 9
UNITED KINGDOM
bey, if any
b(2) Reference ID number (see instructions)
c Country(ies) under whose laws organized and entity type under local tax law
UNITED KINGDOM
CORPORATION
d Date(s) of organization
09 28 12
e Effective date as foreign
disregarded entity
09/28/12
f If benefits under a U.S. tax treaty were claimed with respect to income
of the foreign disregarded entity, enter the treaty and article number
g Country in which principal
business activity is conducted
UNITED KINGDOM
h Principal business
activity
INVESTMENT
INVESTMENT
I Functional currency
UNITED
KINGDOM,POUND
2
Provide the following information for the foreign disregarded entity's a counting period stated above.
a Name, address, and identifying number of branch office or agent (if any) in the
b Name and addrmn Mowing corpecatO depalment. It amenable) of person(e)with CIAStOdY
or the b00kd
cgOortZ: Ct tha ttypOn adeggardni entity. and the location al such bOOKS
United States
and records. i1 °event
ANDREW PRICE
REGENTS WHARF, ALL SAINTS ST
LONDON,
FC N1 9PA
UNITED KINGDOM
3
For the tax owner of the foreign disregarded entity (if different from the filer) provide the following:
a Name and address
f?%
b Annual accounting period covered by the return (see instructions)
c(1) U.S. identifying number, if any
02) Reference ID number (see instructio s)
d Country under whose laws organized
e Functional currency
4
For the direct owner of the foreign disregarded entity (if different from the tax owner provide the following:
a Name and address
b Country under whose laws organized
JMWT ACQUISITION LLP
REGENTS WHARF, ALL SAINTS ST
UNITED KINGDOM
LONDON,
FC N1 9PA
UNITED KINGDOM
5
if any
I d Functional currency
'UNITED KINGDOM, PO
Attach en I:idolization,' chart that identities the name. placement. percentageof ownership. tax classification. andcounty cd organization of all entities in the chain of ownership behtten the tax
Peeler and the loreIgn disregarded entity. and the chore ol ownership between the loreir dieregarded entity end each entity In which the Welch disregarded entity Ninth% or more direct or
:Wiwi Interco'. See inelluclicne.
SEE STATEMENT 77
For Paperwork Reduction Act Notice, see the separate instructions.
Form 8858 (Rev. 12-2013)
312411 12-10.13 LHA
13061007 133415 T-1009
518
2013.04030 BLACK, LEON
T-10094
EFTA01114674
LEON D. & DEBRA BLACK
Form 8858 (Rev. 12-2013)
Page 2
lSchedule C [ Income Statement (see instructions)
Important Report ail information in functional currency in accordance with U.S. GAAP. Also, report each amount in U.S. dollars translated from functional
currency (using GAAP translation rules or the average exchange rate determined under section 989(b)). If the functional currency is the U.S. dollar.
complete only the U.S. Dollars column. See instructions for special rules for foreign disregarded entities that use DAS TM.
If you are using the average exchange rate (determined under section 989(b)), check the following box
Functional Currency
U.S. Dollars
I
Gross receipts or sales (net of returns and allowances)
1
2 Cost of goods sold
2
3 Gross profit (subtract line 2 from line 1)
3
4 Other income
4
5 Total income (add Ines 3 and 4)
5
6 Total deductions
6
7 Other adjustments
7
8 Net income (loss) per books
8
Schedule C-1 I Section 987 Gain or Loss Information
(a)
(b)
Note. See the instructions if there are multiple recipients of remittances
from the foreign disregarded entity.
Amount stated in
functional currency of
foreign disregarded entity
Amount stated in
functional currency
of recipient
1 Remittances from the foreign disregarded entity
2 Section 987 gain (loss) of recipient
2
Yes
No
3 Were all remittances from the foreign disregarded entity treated as made to the direct owner?
4 Did the tax owner change its method of accounting for section 987 gain or loss with respect to remittances from the gweign disregarded
entity during the tax year?
Schedule F I Balance Sheet
Important Report all amounts kt U.S. dollars computed in functional currency and translated into U.S. dollars in accords
See instructions for an exception for foreign disregarded entities that use DASTM.
with U.S. GAAP.
Assets
I
Cash and other current assets
2 Other assets
Ova
Liabilities and
y
3 Total assets
"iv y N
,
4 Liabilities
5 Owner's equity
6 Total liabilities and oymer's equity
1
Schedule G I Other Information
Beginning
annual
accounting period
End of annual
accounting period
1
2
3
44,449,838.
44,449,838.
45,404,959.
45,404,959.
4
5
6
44,449,838.
44,449,838.
45,404,959.
45,404,959.
I
During the tax year, did the foreign disregarded entity own an interest in any trust?
2 During the tax year, did the foreign disregarded entity own at least a 10% interest, directly or indirectly, in any foreign partnership?
3 Answer the following question only if the foreign disregarded entity made its Section to be treated as disregarded from
Its owner during the tax year: Did the tax owner claim a loss with respect to stock or debt of the foreign disregarded entity as a
result of the election?
4 If the interest in the foreign disregarded entity is a separate unit under Reg. 1.1503(d)-1(bX4) or part of a combined separate unit
under reg. 1.1503(d)-1(bX4)(ii) does the separate unit or combined separate unit have a dual consoidated loss as defined in Reg.
1.1503(d)-1(b)(5)(10?
If 'Yes: enter the amount of the dual consolidated
$
Answer question 5a.
Yes
No
X
X
N /A
Form 8858 (Rev. 12-2013)
519
13061007 133415 T-1009
2013.04030 BLACK, LEON
T-10094
EFTA01114675
LEON D. & DEBRA BLACK
Form 8858 (Rev. 12-2013)
Schedule G I Other Information (continued)
Page 3
5a Was any portion of the dual consolidated loss in question 4 taken into account in computing consolidated taxable income for the
year? If "Yes; go to 5b. 'No; skip 5b and 5c
b Was this permitted domestic use of the dual consolidated loss under Reg. 1.1503(d)-6? If 'Yes, see instructions and skip 5c.
It"No," go to 5c
c If this was not a permitted domestic use, was the dual consolidated loss used to compute consolidated taxable income as provided
under Reg. 1.503(d)-4?
If "Yes; enter the separate unit's contribution to the cumulative consolidated Taxable income (cumulative register) as of the
beginning of the lax year Ne. $
See Instructions.
6 During the tax year, did the foreign disregarded entity pay or accrue any foreign tax that was disqualified for credit under
section 901(m)?
7 During the tax year, did the foreign disregarded entity pay or accrue foreign taxes to which section 909 applies, or treat foreign
taxes that were previously suspended under section 909 as no longer suspended?
8 Answer the following question only if the tag owner of the foreign disregarded entity k a controlled foreign corporation
(CFC): Were there any intracompany transactions between the foreign disregarded entity and the CFC or any other branch of the
CFC during the tax year, in which the foreign disregarded entity acted as a manufacturing, selling, or purchasing branch?
Current Earnings and Profits or Taxable Income (see instructions)
Schedule H
Important Enter the amounts on lines 7 through 6 in functional currency.
I
Current year net income or (loss) per foreign books of account
2 Total net additions
3 Total net subtractions
4 Current earnings and profits (or taxable income — see instructions) (Iine 1 plus ire 2
us line 3)
5
DASTM gain or loss (if applicable)
6 Combine lines 4 and 5
7 Current earnings and profits (or taxable income) in U.S. doNars eine 6 translated at the average exchange rate determined under
section 989(b) and the related regulations (see instructions))
Enter exchange rate used for line 7 ►
Yes
No
40;7
1
2
3
4
5
6
7
Form 8858 (Rev. 12-2013)
31,413
V-10.13
520
13061007 133415 T-1009
2013.04030 BLACK, LEON
T-10094
EFTA01114676
Foini 8858
December 2013)
Oepartment of the if esan
Internal Revenue Service
Name of person filing this retu n
LEON D. & DEBRA BLACK
I
Information Return of U.S. Persons With Respect To Foreign Disregarded Entities
Ile Information about Form 8858 and its separate Instructions Is at vAvw.irs.gov/form8858.
Information furnished for the foreign disregarded entitys annual accounting period (see instructions)
men
beginning JAN 1
.2013
. and ending DEC 31
OMB No. 1545-1910
number if mail is not delivered to street address)
Filers tax year beginning
, 20 13 , and ending
DEC 31
.20 13
Important Fill in all applicable lines and schedules. All information must be in English. All amounts must be stated in U.S. dollars unless otherwise indicated.
to Name and address of foreign disregarded entity
JMWT MIDCO LIMITED
REGENTS WHARF, ALL SAINTS ST
LONDON
FC Ni 9
UNITED KINGDOM
"
b 1 U.S. iden
n number if any
b(2) Reference ID number (see instructions)
c Coo ntry(ies) under whose laws organized and entity type under local tax law
UNITED KINGDOM
CORPORATION
d Date(s) of organization
09 12 12
e Effective date as foreign
disregarded entity
09/12/12
1 If benefits under a U.S. tax treaty were claimed with respect to income
of the foreign disregarded entity, enter the treaty and article number
g Country in which principal
business activity is conducted
UNITED KINGDOM
h Principal business
activity
INVESTMENT
I Functional currency
UNITED
KINGDOM, POUND
2
Provide the following information for the foreign disregarded entity's a counting period stated above.
a Name, address, and identifying number of branch office or agent (if any) in the
b Name and addrmn M owing corpecatO d.palmant. appladable) 01 person(S) with CufStOclY
CA MO bOOkdani .A0OftZ: CI Cho ttypOn LICAggard9CI entity. and the Iccallon a such WOKS
United States
and recycle. if afferent
ANDREW PRICE
REGENTS WHARF, ALL SAINTS ST
LONDON,
FC Ni 9PA
UNITED KINGDOM
3
For the tax owner of the foreign disregarded entity (if different from the filer) provide the (okaying:
a Name and address
P
b Annual accounting period covered by the return (see instructions)
c(1) U.S. identifying number, if any
c(2) Reference ID number (see instructio s)
d Country under whose laws organized
e Functional currency
4
For the direct owner of the foreign disregarded entity (if different from the tax owner provide the following:
a Name and address
JMWT TOPCO LIMITED
REGENTS WHARF, ALL SAINTS ST
LONDON,
FC Ni 9PA
UNITED KINGDOM
b Country under whose laws organized
ITED KINGDOM
c U.S. identi n number, if any
K
TFunctional currency
ITED KINGDOM, PO
5
Attach an cifprizatronal chart that identifies the note. placement. percentage of ownership. tax asssilication, and county of crganization of all entities in the chain of ownership betwaen the tax
owner and the lorggn disregarded entity. and the chain al CumerilhiP between the loreigi disregarded entity and each entity In which the foreir disregarded entity hese 10% or more direct or
:Wiwi 'Mortal. See inatiuclicns.
SEE STATEMENT 78
For Paperwork Reduction Act Notice, see the separate Instructions.
Form 8858 (Rev. 12-2013)
312411 12-10.13 IHA
13061007 133415 T-1009
521
2013.04030 BLACK, LEON
T-10094
EFTA01114677
LEON D. & DEBRA BLACK
Form 8858 (Rev. 12-2013)
Page 2
Schedule C I Income Statement (see instructions)
Important Report all information in functional currency in accordance with U.S. GAAP. Also, report each amou
—nitn U.S. dollars transla
functional
currency (using GAAP translation rules or the average exchange rate determined under section 989(b)). If the functional currency is the U.S. dollar.
complete only the U.S. Dollars column. See instructions for special rules for foreign disregarded entities that use DASTM.
If you are using the average exchange rate (determined under section 989(b)), check the following box
Functional Currency
U.S. Dollars
1 Gross receipts or sales (net of returns and allowances)
1
2 Cost of goods sold
2
3 Gross profit (subtract line 2 from line 1)
3
4 Other income
4
5
Total income (add Ines 3 and 4)
5
6 Total deductions
6
7
Other adjustments
7
8
Net income (loss) per books
8
I-Schedule C-1 I Section 987 Gain or Loss Information
(a)
(b)
Note. See the instructions if there are multiple recipients of remittances
from the foreign disregarded entity.
Amount stated in
functional currency of
foreign disregarded entity
Amount stated in
functional currency
of recipient
1 Remittances from the foreign disregarded entity
2 Section 987 gain (loss) of recipient
2
Yes
No
3 Were all remittances from the foreign disregarded entity treated as made to the direct owner?
4 Did the tax owner change its method of accounting for section 987 gain or loss with respect to remittances from the foreign disregarded
entity during the tax year?
..
Schedule F I Balance Sheet
Important Report all amounts in U.S. dollars computed in functional currency and translated into U.S. dollars in accordance with U.S. GAAP.
See instructions loran exception for foreign disregarded entities that use DASTM.
Assets
Beginning of annual
accounting period
(
End of annual
accounting period
1 Cash and other current assets
kiimut
1
2 Other assets
3 Total assets
2 66,674,757. 68,107,438.
3 66,674,757. 68,107,438.
Liabilities
Car:nefifty
%
and
4 Liabilities
4 22,882,533. 25,426,777.
5 Owner's equity
5 43,792,224. 42,680,661.
6 Total liabilities and owner's equity
6 66,674,757. 68,107,438.
Schedule G I Other Information
1 During the tax year, did the foreign disregarded entity own an interest in any trust?
2 During the tax year, did the foreign disregarded entity own at least a 10% interest, directly or indirectly, in any foreign partnership?
3 Answer the following question only if the foreign disregarded entity made its Section to be treated as disregarded from
its owner during the tax year: Did the tax owner claim a loss with respect to stock or debt of the foreign disregarded entity as a
result of the election?
4 If the interest in the foreign disregarded entity is a separate unit under Reg. 1.1503(d)-1(bX4) or part of a combined separate unit
under reg. 1.1503(d)-1(bX4)(ii) does the separate unit or combined separate unit have a dual consoidated loss as defined in Reg.
1.1503(d)-1(b)(5)(10?
If "Yes; enter the amount of the dual consolidated loss► $
Answer question 5a.
Yes
No
X
X
N /A
Form 8858 (Rev. 12-2013)
31,412
12-10.13
13061007 133415 T-1009
522
2013.04030 BLACK, LEON
T-10094
EFTA01114678
LEON D. & DEBRA BLACK
Form 8858 (Rev. 12-2013)
Schedule G I Other Information (continued)
Page 3
5a Was any portion of the dual consolidated loss in question 4 taken into account in computing consolidated taxable income for the
year? If "Yes; go to 5b. 'No; skip 5b and 5c
b Was this permitted domestic use of the dual consolidated loss under Reg. 1.1503(d)-6? If 'Yes, see instructions and skip 5c.
It"No," go to 5c
c If this was not a permitted domestic use, was the dual consolidated loss used to compute consolidated taxable income as provided
under Reg. 1.503(d)-4?
If "Yes; enter the separate unit's contribution to the cumulative consolidated Taxable income (cumulative register) as of the
beginning of the lax year Ne. $
See Instructions.
6 During the tax year, did the foreign disregarded entity pay or accrue any foreign tax that was disqualified for credit under
section 901(m)?
7 During the tax year, did the foreign disregarded entity pay or accrue foreign taxes to which section 909 applies, or treat foreign
taxes that were previously suspended under section 909 as no longer suspended?
8 Answer the following question only if the tag owner of the foreign disregarded entity k a controlled foreign corporation
(CFC): Were there any intracompany transactions between the foreign disregarded entity and the CFC or any other branch of the
CFC during the tax year, in which the foreign disregarded entity acted as a manufacturing, selling, or purchasing branch?
Current Earnings and Profits or Taxable Income (see instructions)
Schedule H
Important Enter the amounts on lines 7 through 6 in functional currency.
I
Current year net income or (loss) per foreign books of account
2 Total net additions
3 Total net subtractions
4 Current earnings and profits (or taxable income — see instructions) (Iine 1 plus ire 2
us line 3)
5
DASTM gain or loss (if applicable)
6 Combine lines 4 and 5
7 Current earnings and profits (or taxable income) in U.S. doNars eine 6 translated at the average exchange rate determined under
section 989(b) and the related regulations (see instructions))
Enter exchange rate used for line 7 ►
Yes
No
40;7
1
2
3
4
5
6
7
Form 8858 (Rev. 12-2013)
31,413
V-10.13
523
13061007 133415 T-1009
2013.04030 BLACK, LEON
T-10094
EFTA01114679
Form 8858
Information Return of U.S. Persons With Respect To Foreign Disregarded Entities
lb. Information about Form 8858 and its separate instructions Is at vAvw.lrs.gov/form885&
OMB No. 1545-1910
0a.ey. December 2013)
Department of the Treasury
Internal Revenue Service
Name of person filing this return
Flier's Identifying number
LEON D. & DEBRA BLACK
Information furnished for the foreign disregarded entitys annual accounting period (see instructions)
Attachment
beginning JAN 1
.2013
. and ending DEC 31
.20 13
$80taance No 140
x number it mail is not delivered to street address)
Filer's tax year beginning
JAN
, 20 13 , and ending
DEC 31
,2013
Important Fill in all applicable lines and schedules. All information must be in English. All amounts must be stated in U.S. dollars unless otherwise indicated.
la Name and address of foreign disregarded entity
6(1) U.S. identifying number, if any
MARLYEBONE RETAIL LIMITED
REGENTS WHARF, ALL SAINTS ST
b(2) Reference ID number (see instructions)
LONDON
N1 9PA
UNITED KINGDOM
e Country(ies) under whose laws organized and entity type under local tax law
UNITED KINGDOM
CORPORATION
d Date(s) of organization
10 03 12
e Effective date as foreign
disregarded entity
10/03/12
I Functional currency
If benefits under a U.S. tax treaty were claimed with respect to income
of the foreign disregarded entity, enter the treaty and article number
g Country in which principal
business activity is conducted
UNITED KINGDOM
it Principal business
activity
RETAIL BOOKS UNITED
KINGDOM, POUND
2
Provide the following information for the foreign disregarded entity's a counting period stated above.
a Name, address, and identifying number of branch office or agent (if any) in the
b NAT,. and adotwn Procuring corporato dapxtrnant. It applwab90 01 PerS0001 with mated/
United States
44 tne books are records of the tenser, oegegardeci entity. AM MA location 01 such books
-
amirecvos.uoe4gem
ANDREW PRICE
REGENTS WHARF, ALL SAINTS ST
LONDON,
N1 9PA
UNITED KINGDOM
3
For the tax owner of the foreign disregarded entity (if different from the filer) provide the following:
a Name and address
b Annual accounting period covered by the return (see instructions)
e(l) U.S. identifying number, if any
e(2) Reference ID number (see instructio s)
d Country under whose laws organized
e Functional currency
4
For the direct owner of the foreign disregarded entity (if different from the tax owner provide the following:
a Name and address
PHAIDON PRESS LTD.
ti Country under whose laws organized
REGENTS WHARF,
LONDON,
N1
ALL
9PA
SAINTS ST
UNITED KINGDOM
UNITED KINGDOM
e U.S. identifying number, if any
currency
IJNFunctional
ITED KINGDOM,PO
5
Attach an organizational chart that identities the name. placement percentage of ownership. tax dassilication. wadcountry of organization of all entities in Ihe chain of ownership between the tax
ma and the foreign disregarded entity. and the cheil of ernership between the lorelgi disregarded entity end each entity In which the Sorelr disregarded entity Wise 1094 or more direct or
ndieci nterest See. instructions.
SEE STATEMENT 79
For Paperwork Reduction Act Notice, see the separate instructions.
1-07118858 (Rev. 12-2013)
512411 12-10.15 IHA
13061007 133415 T-1009
524
2013.04030 BLACK, LEON
T-10094
EFTA01114680
LEON D. & DEBRA BLACK
Form 8858 (Rev. 12-2013)
Page 2
Schedule C I Income Statement (see instructions)
Important Report all information in functional currency in accordance with U.S. GAAP. Also, report each amou
—nitn U.S. dollars transla
functional
currency (using GAAP translation rules or the average exchange rate determined under section 989(b)). If the functional currency is the U.S. dollar.
complete only the U.S. Dollars column. See instructions for special rules for foreign disregarded entities that use DASTM.
If you are using the average exchange rate (determined under section 989(b)), check the following box
Functional Currency
U.S. Dollars
1 Gross receipts or sales (net of returns and allowances)
1
160,322.
2 Cost of goods sold
2
73,344.
3 Gross profit (subtract line 2 from line 1)
3
86,978.
4 Other income
4
5
Total income (add Ines 3 and 4)
5
86,978.
6 Total deductions
6
109,200.
7
Other adjustments
7
8
Net income (loss) per books
8
-22,222.
'Schedule C-1 I Section 987 Gain or Loss Information
(a)
(b)
Note. See the instructions if there are multiple recipients of remittances
from the foreign disregarded entity.
Amount stated in
functional currency of
foreign disregarded entity
Amount stated in
functional currency
of recipient
1 Remittances from the foreign disregarded entity
1
2 Section 987 gain (loss) of recipient
2
Yes
No
3 Were all remittances from the foreign disregarded entity treated as made to the direct owner?
4 Did the tax owner change its method of accounting for section 987 gain or loss with respect to remittances from the foreign disregarded
entity during the tax year?
..
w
Schedule F I Balance Sheet
Important Report all amounts in U.S. dollars computed in functional currency and translated into U.S. dollars in accordance with U.S. GAAP.
See instructions loran exception for foreign disregarded entities that use DASTM.
1 Cash and other current assets
2 Other assets
e
Liabilities and Ov:n
filty
%C
O
3 Total assets
4 Liabilities
5 Owner's equity
6 Total liabilities and owner's equity
Schedule G I Other Information
Beginning of annual
accounting period
1
6,572.
2
38,038.
3
44,610.
4
547,898.
5
-503,288.
6
44,610.
End of annual
accounting period
28,824.
32,871.
61,695.
599,168.
—537,473.
61,695.
1 During the tax year, did the foreign disregarded entity own an interest in any trust?
2 During the tax year, did the foreign disregarded entity own at least a 10% interest, directly or indirectly, in any foreign partnership?
3 Answer the following question only if the foreign disregarded entity made its Section to be treated as disregarded from
its owner during the tax year: Did the tax owner claim a loss with respect to stock or debt of the foreign disregarded entity as a
result of the election?
4 If the interest in the foreign disregarded entity is a separate unit under Reg. 1.1503(d)-1(bX4) or part of a combined separate unit
under reg. 1.1503(d)-1(bX4)(ii) does the separate unit or combined separate unit have a dual consoidated loss as defined in Reg.
1.1503(d)-1(b)(5)(10?
If "Yes; enter the amount of the dual consolidated loss► $
Answer question 5a.
Yes
No
X
X
N /A
Form 8858 (Rev. 12-2013)
31,412
12-10.13
13061007 133415 T-1009
525
2013.04030 BLACK, LEON
T-10094
EFTA01114681
LEON D. & DEBRA BLACK
Form 8858 (Rev. 12-2013)
Schedule G I Other Information (continued)
Page 3
5a Was any portion of the dual consolidated loss in question 4 taken into account in computing consolidated taxable income for the
year? If "Yes; go to 5b. 'No; skip 5b and 5c
b Was this permitted domestic use of the dual consolidated loss under Reg. 1.1503(d)-6? If 'Yes, see instructions and skip 5c.
It"No," go to 5c
c If this was not a permitted domestic use, was the dual consolidated loss used to compute consolidated taxable income as provided
under Reg. 1.503(d)-4?
If "Yes; enter the separate unit's contribution to the cumulative consolidated Taxable income (cumulative register) as of the
beginning of the lax year Ne. $
See Instructions.
6 During the tax year, did the foreign disregarded entity pay or accrue any foreign tax that was disqualified for credit under
section 901(m)?
7 During the tax year, did the foreign disregarded entity pay or accrue foreign taxes to which section 909 applies, or treat foreign
taxes that were previously suspended under section 909 as no longer suspended?
8 Answer the following question only if the tag owner of the foreign disregarded entity k a controlled foreign corporation
(CFC): Were there any intracompany transactions between the foreign disregarded entity and the CFC or any other branch of the
CFC during the tax year, in which the foreign disregarded entity acted as a manufacturing, selling, or purchasing branch?
Current Earnings and Profits or Taxable Income (see instructions)
Schedule H
Important Enter the amounts on lines 7 through 6 in functional currency.
I
Current year net income or (loss) per foreign books of account
2 Total net additions
3 Total net subtractions
4 Current earnings and profits (or taxable income — see instructions) (Iine 1 plus ire 2
us line 3)
5
DASTM gain or loss (if applicable)
6 Combine lines 4 and 5
7 Current earnings and profits (or taxable income) in U.S. doNars eine 6 translated at the average exchange rate determined under
section 989(b) and the related regulations (see instructions))
Enter exchange rate used for line 7 ►
Yes
No
40;7
1
2
3
4
5
6
7
Form 8858 (Rev. 12-2013)
31,413
V-10.13
526
13061007 133415 T-1009
2013.04030 BLACK, LEON
T-10094
EFTA01114682
Form 8858
►
Information Return of U.S. Persons With Respect To Foreign Disregarded Entities
Information about Form 8858 and its separate instructions Is at vAvw.Irs.gov/fortn885&
OMB No. 1545-1910
BERLIN
12043
GERMANY
e Country(ies) under whose laws organized and entity type under local tax law
GERMANY
CORPORATION
geev.D
2013)
Oepartment of the Tie...laity
internal Revenue Service
Name of person filing this return
Filer's Identifying number
LEON D. & DEBRA BLACK
Information furnished for the foreign disregarded entitys annual accounting period (see instructions)
Attechinent
beginning JAN 1
,m13
. and ending DEC 31
.
Dacitaance No 140
2013
x number it mail is not delivered to street address)
year egin
, 20 1 3 ,and ending
DEC 31
,20 13
Important Fill in all applicable lines and schedules. All information must be in English. All amounts must be stated in U.S. dollars unless otherwise indicated.
la Name and address of foreign disregarded entity
6(1) U.S. identifying number, if any
PHAIDON VERLAG GMBH
INNSTRA030
b(2) Reference ID number (see instructions)
d Date(s) of organization
10 03 12
e Effective date as foreign
disregarded entity
10/03/12
I
Functional currency
If benefits under a U.S. tax treaty were claimed with respect to income
of the foreign disregarded entity, enter the treaty and article number
g Country in which principal
business activity is conducted
GERMANY
h Principal business
activity
PUBLISHING
EUROPEAN
UNION, EURO
2
Provide the following information for the foreign disregarded entity's a counting petdd stated above.
a Name, address, and identifying number of branch office or agent (if any) in the
b NAT,. and adotmc tincturing corporate depalmant. It appicatae) of P.S00(e) wen mated/
ot the books ar+i concede of Ihe forcer owegarded entity. AM the location of such boots
United States
awreopfus.iice4gem
ANDREW PRICE
REGENTS WHARF, ALL SAINTS ST
LONDON,
N1 9PA
UNITED KINGDOM
3
For the tax owner of the foreign disregarded entity (if different from the filer) provide the following:
a Name and address
f?%
b Annual accounting period covered by the return (see instructions)
e(1) U.S. identifying number, if any
e(2) Reference ID number (see instructio s)
d Country under whose laws organized
e Functional currency
4
For the direct owner of the foreign disregarded entity (if different from the tax owner provide the following:
a Name and address
PHAIDON PRESS LTD.
b Country under whose laws organized
REGENTS WHARF,
LONDON,
N1
ALL
9PA
SAINTS ST
UNITED KINGDOM
UNITED KINGDOM
e U.S. identifying number, if any
currency
14 1Functional
ITED KINGDOM,PO
5
Attach an orepnizational chart that identities the name. placement. percentage of ownership. tax classification. endcounty of orepnization of all entities in the chain of ownership between the tax
onmer and the loreign disregarded entity. and the civil of ownership between the loreir disregarded entity end each entity In which the foreign disregarded entity has a 11)94 or more direct or
ndieci nines,. See. instructions.
SEE STATEMENT 80
For Paperwork Reduction Act Notice, see the separate instructions.
Fain 8858 (Rev. 12-2013)
512411 12-10.15 IHA
13061007 133415 T-1009
527
2013.04030 BLACK, LEON
T-10094
EFTA01114683
LEON D. & DEBRA BLACK
Form 8858 (Rev. 12-2013)
Page 2
Schedule C I Income Statement (see instructions)
Important Report all information in functional currency in accordance with U.S. GAAP. Also, report each amou
—nitn U.S. dollars transla
functional
currency (using GAAP translation rules or the average exchange rate determined under section 989(b)). If the functional currency is the U.S. dollar.
complete only the U.S. Dollars column. See instructions for special rules for foreign disregarded entities that use DASTM.
If you are using the average exchange rate (determined under section 989(b)), check the following box
D6
1 Gross receipts or sales (net of returns and allowances)
2 Cost of goods sold
3 Gross profit (subtract line 2 from line 1)
4 Other income
5
Total income (add Ines 3 and 4)
6 Total deductions
7
Other adjustments
8
Net income (loss) per books
Functional Currency
U.S. Dollars
1
2
3
4
5
6
105,397.
7
8
-105,397.
I-Schedule C-1 I Section 987 Gain or Loss Information
(a)
(b)
Note. See the instructions if there are multiple recipients of remittances
Amount stated in
Amount stated in
from the foreign disregarded entity.
functional currency of
functional currency
foreign disregarded entity
of recipient
1 Remittances from the foreign disregarded entity
1
2 Section 987 gain (loss) of recipient
2
Yes
No
3 Were all remittances from the foreign disregarded entity treated as made to the direct owner?
4 Did the tax owner change its method of accounting for section 987 gain or loss with respect to remittances from the foreign disregarded
entity during the tax year?
..
Schedule F I Balance Sheet
Important Report all amounts in U.S. dollars computed in functional currency and translated into U.S. dollars in accordance with U.S. GAAP.
See instructions loran exception for foreign disregarded entities that use DASTM.
1 Cash and other current assets
2 Other assets
e
Liabilities and Ov:n
filty
%C
O
3 Total assets
4 Liabilities
5 Owner's equity
6 Total liabilities and owner's equity
Schedule G I Other Information
Beginning of annual
accounting period
End of annual
accounting period
1
2
3
5,0[5.
135,458.
456,389.
591,847.
399,621.
404,636.
4
5
6
877,925.
1,195,860.
-473,289.
-604,013.
404,636.
591,847.
1 During the tax year, did the foreign disregarded entity own an interest in any trust?
2 During the tax year, did the foreign disregarded entity own at least a 10% interest, directly or indirectly, in any foreign partnership?
3 Answer the following question only if the foreign disregarded entity made its Section to be treated as disregarded from
its owner during the tax year: Did the tax owner claim a loss with respect to stock or debt of the foreign disregarded entity as a
result of the election?
4 If the interest in the foreign disregarded entity is a separate unit under Reg. 1.1503(d)-1(bX4) or part of a combined separate unit
under reg. 1.1503(d)-1(bX4)(ii) does the separate unit or combined separate unit have a dual consoidated loss as defined in Reg.
1.1503(d)-1(b)(5)(10?
If "Yes; enter the amount of the dual consolidated loss► $
Answer question 5a.
Yes
No
X
X
N /A
Form 8858 (Rev. 12-2013)
31,412
12-10.13
13061007 133415 T-1009
528
2013.04030 BLACK, LEON
T-10094
EFTA01114684
LEON D. & DEBRA BLACK
Form 8858 (Rev. 12-2013)
Schedule G I Other Information (continued)
Page 3
5a Was any portion of the dual consolidated loss in question 4 taken into account in computing consolidated taxable income for the
year? If "Yes; go to 5b. 'No; skip 5b and 5c
b Was this permitted domestic use of the dual consolidated loss under Reg. 1.1503(d)-6? If 'Yes, see instructions and skip 5c.
It"No," go to 5c
c If this was not a permitted domestic use, was the dual consolidated loss used to compute consolidated taxable income as provided
under Reg. 1.503(d)-4?
If "Yes; enter the separate unit's contribution to the cumulative consolidated Taxable income (cumulative register) as of the
beginning of the lax year Ne. $
See Instructions.
6 During the tax year, did the foreign disregarded entity pay or accrue any foreign tax that was disqualified for credit under
section 901(m)?
7 During the tax year, did the foreign disregarded entity pay or accrue foreign taxes to which section 909 applies, or treat foreign
taxes that were previously suspended under section 909 as no longer suspended?
8 Answer the following question only if the tag owner of the foreign disregarded entity k a controlled foreign corporation
(CFC): Were there any intracompany transactions between the foreign disregarded entity and the CFC or any other branch of the
CFC during the tax year, in which the foreign disregarded entity acted as a manufacturing, selling, or purchasing branch?
Current Earnings and Profits or Taxable Income (see instructions)
Schedule H
Important Enter the amounts on lines 7 through 6 in functional currency.
I
Current year net income or (loss) per foreign books of account
2 Total net additions
3 Total net subtractions
4 Current earnings and profits (or taxable income — see instructions) (Iine 1 plus ire 2
us line 3)
5
DASTM gain or loss (if applicable)
6 Combine lines 4 and 5
7 Current earnings and profits (or taxable income) in U.S. doNars eine 6 translated at the average exchange rate determined under
section 989(b) and the related regulations (see instructions))
Enter exchange rate used for line 7 ►
Yes
No
40;7
1
2
3
4
5
6
7
Form 8858 (Rev. 12-2013)
31,413
V-10.13
529
13061007 133415 T-1009
2013.04030 BLACK, LEON
T-10094
EFTA01114685
Form 8858
Ow. December 2013)
Clepartment of the Tit-awry
Intanal Revenue Service
Name of person filing this return
Filer's Identifying number
LEON D. & DEBRA BLACK
Information Return of U.S. Persons With Respect To Foreign Disregarded Entities
► Information about Form 8858 and its separate instructions Is at vAvw.lrs.gov/form885&
Information furnished for the foreign disregarded entitys annual accounting period (see instructions)
bernninl JAN 1
2013
.andendin DEC 31
.2013
OMB No. 1545-1910
Attachment
Sequence No. 140
Number street. and room or suite no.
box number it mail is not delivered to street address)
Filer's tax year beginning
JAN 1
20 13 , and ending
DEC 31
, 20 13
Important Fill in all applicable lines and schedules. AD information must be in English. All amounts must be stated in U.S. dollars unless otherwise indicated.
la Name and address of foreign disregarded entity
PHAIDON PRESS LTD SARL
VIALE BIANCA MARIE 23
MILAN
ITALY
e Country(ies) under whose laws organized and entity type under local tax law
ITALY
CORPORATION
20122
big U.S. identifying number, if any
b(2) Reference ID number (see instructions)
d Date(s) of organization
10 03 12
e Effective date as foreign
disregarded entity
10/03/12
I Functional currency
f If benefits under a U.S. tax treaty were claimed with respect to income
of the foreign disregarded entity, enter the treaty and article number
g Country in which principal
business activity is conducted
ITALY
2
Provide the following information for the foreign disregarded entity's a counting period stated above.
a Name, address, and identifying number of branch office or agent (if any) in the
United States
h Principal business
activity
PUBLISHING
.1k
EUROPEAN
UNION, EURO
b NAT,. and arktm:11ncAkang CCAPCIAIG dap.atroont. It aogewbk0 0111.50001wIth 0.44100,
44 tne books are !cowls of the foremen oaregerded entity. AM the I0Cat1011 ol such books
and records. it deerent
ANDREW PRICE
REGENTS WHARF, ALL SAINTS ST
LONDON,
Ni 9PA
UNITED KINGDOM
3
For the tax owner of the foreign disregarded entity (if different from the filer) provide the following:
a Name and address
b Annual accounting period covered by the return (see instructions)
c(1) U.S. identifying number, if any
e(2) Reference ID number (see instructio s)
d Country under whose laws organized
e Functional currency
4
For the direct owner of the foreign disregarded entity (if different from the tax owner provide the following:
a Name and address
PHAIDON PRESS LTD.
b Country under whose laws organized
REGENTS WHARF,
LONDON,
Ni
ALL
9PA
SAINTS ST
UNITED KINGDOM
UNITED KINGDOM
e U.S. identifying number, if any
currency
141Functional
ITED KINGDOM,PO
5
Attach en organizational chart that identities the name. placement percentageof ownership. tax classilication. and county of organization of all entities in the chain of ownership between the tax
chmer and the foreign disregarded entity. and the chain of Garner shlp between the lorelr disregarded entity end each entity In which the40441r dieregatcled entity Ilea a 1094 or mote direct or
ndieci interest. See instructions.
SEE STATEMENT 81
For Paperwork Reduction Act Notice, see the separate instructions.
Fern 8858 (Rev. 12-2013)
512411 12-10.15 IHA
530
13061007 133415 T-1009
2013.04030 BLACK, LEON
T-10094
EFTA01114686
LEON D. & DEBRA BLACK
Form 8858 (Rev. 12-2013)
Page 2
ScheduleS4 Income Statement (see instructions)
Important Repon a I information in functional currency in accordance with U.S. GAAP. Also, report each amou
—nttn U.S. dollars transla
functional
currency (using GAAP translation rules or the average exchange rate determined under section 989(b)). If the functional currency is the U.S. dollar.
complete only the U.S. Dollars column. See instructions for special rubs for foreign disregarded entities that use DASTM.
If you are using the average exchange rate (determined under section 989(b)), check the following box
D6
1 Gross receipts or sales (net of returns and allowances)
2 Cost of goods sold
3 Gross profit (subtract line 2 from line 1)
4 Other income
5
Total income (add Ines 3 and 4)
6 Total deductions
7
Other adjustments
8
Net income (loss) per books
Functional Currency
U.S. Dollars
1
2
3
4
5
6
15,041.
7
8
-15,041.
I-Schedule C-1 I Section 987 Gain or Loss Information
(a)
(b)
Note. See the instructions if there are multiple recipients of remittances
Amount stated in
Amount stated in
from the foreign disregarded entity.
functional currency of
functional currency
foreign disregarded entity
of recipient
1 Remittances from the foreign disregarded entity
2 Section 987 gain (loss) of recipient
2
Yes
No
3 Were all remittances from the foreign disregarded entity treated as made to the direct owner?
4 Did the tax owner change its method of accounting for section 987 gain or loss with respect to remittances from the foreign disregarded
entity during the tax year?
...
Schedule F I Balance Sheet
Important Report all amounts in U.S. dollars computed in functional currency and translated into U.S. dollars in accordance with U.S. GAAP.
See instructions loran exception for foreign disregarded entities that use DASTM.
(
Assets
?lee
Beginning of annual
accounting period
End of annual
accounting period
1 Cash and other current assets
1
2 Other assets
2
421,910.
472,692.
3 Total assets
3
421,910.
472,692.
Liabilities
Car:nefifty
%
and
4 Liabilities
4
407,939.
472,914.
5 Owner's equity
5
13,971.
-222.
6 Total liabilities and owner's equity
6
421,910.
472,692.
Schedule G I Other Information
1 During the tax year, did the foreign disregarded entity own an interest in any trust?
2 During the tax year, did the foreign disregarded entity own at least a 10% interest, directly or indirectly, in any foreign partnership?
3 Answer the following question only if the foreign disregarded entity made its election to be treated as disregarded from
Its owner during the tax year: Did the tax owner claim a loss with respect to stock or debt of the foreign disregarded entity as a
result of the election?
4 If the interest in the foreign disregarded entity is a separate unit under Reg. 1.1503(d)-1(bX4) or part of a combined separate unit
under reg. 1.1503(d)-1(bX4)(ii) does the separate unit or combined separate unit have a dual consoidated loss as defined in Reg.
1.1503(d)-1(b)(5)(9)?
If "Yes; enter the amount of the dual consolidated loss► $
Answer question 5a.
Form 8858 (Rev. 12-2013)
Yes
No
X
X
N /A
31,412
12-10.13
531
13061007 133415 T-1009
2013.04030 BLACK, LEON
T-10094
EFTA01114687
LEON D. & DEBRA BLACK
Form 8858 (Rev. 12-2013)
Schedule G I Other Information (continued)
Page 3
5a Was any portion of the dual consolidated loss in question 4 taken into account in computing consolidated taxable income for the
year? If "Yes; go to 5b. 'No; skip 5b and 5c
b Was this permitted domestic use of the dual consolidated loss under Reg. 1.1503(d)-6? If 'Yes, see instructions and skip 5c.
It"No," go to 5c
c If this was not a permitted domestic use, was the dual consolidated loss used to compute consolidated taxable income as provided
under Reg. 1.503(d)-4?
If "Yes; enter the separate unit's contribution to the cumulative consolidated Taxable income (cumulative register) as of the
beginning of the lax year Ne. $
See Instructions.
6 During the tax year, did the foreign disregarded entity pay or accrue any foreign tax that was disqualified for credit under
section 901(m)?
7 During the tax year, did the foreign disregarded entity pay or accrue foreign taxes to which section 909 applies, or treat foreign
taxes that were previously suspended under section 909 as no longer suspended?
8 Answer the following question only if the tag owner of the foreign disregarded entity k a controlled foreign corporation
(CFC): Were there any intracompany transactions between the foreign disregarded entity and the CFC or any other branch of the
CFC during the tax year, in which the foreign disregarded entity acted as a manufacturing, selling, or purchasing branch?
Current Earnings and Profits or Taxable Income (see instructions)
Schedule H
Important Enter the amounts on lines 7 through 6 in functional currency.
I
Current year net income or (loss) per foreign books of account
2 Total net additions
3 Total net subtractions
4 Current earnings and profits (or taxable income — see instructions) (Iine 1 plus ire 2
us line 3)
5
DASTM gain or loss (if applicable)
6 Combine lines 4 and 5
7 Current earnings and profits (or taxable income) in U.S. doNars eine 6 translated at the average exchange rate determined under
section 989(b) and the related regulations (see instructions))
Enter exchange rate used for line 7 ►
Yes
No
40;7
1
2
3
4
5
6
7
Form 8858 (Rev. 12-2013)
31,413
V-10.13
532
13061007 133415 T-1009
2013.04030 BLACK, LEON
T-10094
EFTA01114688
Form 8858
Information Return of U.S. Persons With Respect To Foreign Disregarded Entities
II. Information about Form 8858 and its separate instructions Is at vAvw.lrs.gov/form885&
OMB No. 1545-1910
tRev. December 2013)
IDepartment of the Treasury
Internal Revenue Service
Name of person filing this return
LEON D. & DEBRA BLACK
Information furnished for the foreign disregarded entitys annual accounting period (see instructions)
Attechinent
beginning JAN 1
.2013
. and ending DEC 31
.20 13
Sacitaance No 140
Filer's Identifying number
tuber it mail is not delivered to street address)
Filer's tax year beginning
JAN
, 20 13 , and ending
DEC 31
,2013
Important Fill in all applicable lines and schedules. AD information must be in English. All amounts must be stated in U.S. dollars unless otherwise indicated.
la Name and address of foreign disregarded entity
PHAIDON PRESS PTY
LEVEL 19 2 MARKET STREE
SYDNEY
AUSTRALIA
e Country(ies) under whose laws organized and entity type under local tax law
AUSTRALIA
CORPORATION
NSW 200
b(I) U.S. identifying number, if any
b(2) Reference ID number (see instructions)
d Date(s) of organization
10 03 12
e Effective date as foreign
disregarded entity
10/03/12
I Functional currency
f If benefits under a U.S. tax treaty were claimed with respect to income
of the foreign disregarded entity, enter the treaty and article number
g Country in which principal
business activity is conducted
AUSTRIA
b Principal business
activity
PUBLISHING
AUSTRALIA,
DOLLAR
2
Provide the following information for the foreign disregarded entity's a counting period stated above.
a Name, address, and identifying number of branch office or agent (if any) in the
b NAT,. and eactmo ilnduelng corporate dapdtrnent. It applicalsR0 of ParS0001 with O.44t0O,
United States
44 tne books ard wards of the forams oedegarmaa entity. AM Ire location a such books
and records. it orfrorent
ANDREW PRICE
REGENTS WHARF, ALL SAINTS ST
LONDON,
N1 9PA
UNITED KINGDOM
3
For the tax owner of the foreign disregarded entity (if different from the filer) provide the following:
a Name and address
b Annual accounting period covered by the return (see instructions)
e(1) U.S. identifying number, if any
e(2) Reference ID number (see instructio s)
d Country under whose laws organized
e Functional currency
4 For the direct owner of the foreign disregarded entity (if different from the tax owner provide the following:
a Name and address
PHAIDON PRESS LTD.
b Country under whose laws organized
REGENTS WHARF,
LONDON,
N1
ALL
9PA
SAINTS ST
UNITED KINGDOM
UNITED KINGDOM
e U.S. identifying number, if any
currency
ILINFunctional
ITED KINGDOM,PO
5
Attach en oregnizational chart that identities the name. placement. percentage of ownership. tax classification. endcountry of organization of all entities in the chain of ownership between Ihe tax
cremw and the loreign disregarded entity. and the civil of ownership between the loreir disregarded entity end each entity In which the foreign disregarded entity has a 11)% or more direct or
ndieci interest. See. instructions.
SEE STATEMENT 82
For Paperwork Reduction Act Notice, see the separate instructions.
Fern 8858 (Rev. 12-2013)
512411 12-10.15 IHA
13061007 133415 T-1009
533
2013.04030 BLACK, LEON
T-10094
EFTA01114689
LEON D. & DEBRA BLACK
Form 8858 (Rev. 12-2013)
Page 2
lSchedule C [ Income Statement (see instructions)
Important Report ail information in functional currency in accordance with U.S. GAAP. Also, report each amount in U.S. dollars translated from functional
currency (using GAAP translation rules or the average exchange rate determined under section 989(b)). If the functional currency is the U.S. dollar.
complete only the U.S. Dollars column. See instructions for special rules for foreign disregarded entities that use DAS TM.
If you are using the average exchange rate (determined under section 989(b)), check the following box
D6
Functional Currency
U.S. Dollars
1 Gross receipts or sales (net of returns and allowances)
1
2 Cost of goods sold
2
3 Gross profit (subtract line 2 from line 1)
3
4 Other income
4
5 Total income (add Ines 3 and 4)
5
6 Total deductions
6
7 Other adjustments
7
8 Net income (loss) per books
8
Schedule C-1 I Section 987 Gain or Loss Information
(a)
(b)
Note. See the instructions if there are multiple recipients of remittances
from the foreign disregarded entity.
Amount stated in
functional currency of
foreign disregarded entity
Amount stated in
functional currency
of recipient
1 Remittances from the foreign disregarded entity
1
2 Section 987 gain (loss) of recipient
2
Yes
No
3 Were all remittances from the foreign disregarded entity treated as made to the direct owner?
4 Did the tax owner change its method of accounting for section 987 gain or loss with respect to remittances from the gweign disregarded
entity during the tax year?
Schedule F I Balance Sheet
Important Report all amounts kt U.S. dollars computed in functional currency and translated into U S. dollars in accords
See instructions for an exception for foreign disregarded entities that use DASTM.
with U.S. GAAP.
Assets
1 Cash and other current assets
2 Other assets
3 Total assets
4 Liabilities
5 Owner's equity
6 Total liabilities and ovmer's equity
Schedule G I Other Information
8eginnin
annual
accounting period
1
3,393.
2
3
3,393.
4
9,685.
5
-6,292.
6
3,393.
End of annual
accounting period
7,581.
7,581.
13,001.
-5,420.
7,581.
1 During the tax year, did the foreign disregarded entity own an interest in any trust?
2 During the tax year, did the foreign disregarded entity own at least a 10% interest, directly or indirectly, in any foreign partnership?
3 Answer the following question only if the foreign disregarded entity made its Section to be treated as disregarded from
Its owner during the tax year: Did the tax owner claim a loss with respect to stock or debt of the foreign disregarded entity as a
result of the election?
4 If the interest in the foreign disregarded entity is a separate unit under Reg. 1.1503(d)-1(bX4) or part of a combined separate unit
under reg. 1.1503(d)-1(bX4)(ii) does the separate unit or combined separate unit have a dual consoidated loss as defined in Reg.
1.1503(d)-1(b)(5)(9)?
If 'Yes; enter the amount of the dual consolidated
$
Answer question 5a.
Yes
No
X
X
N /A
Form 8858 (Rev. 12-2013)
534
13061007 133415 T-1009
2013.04030 BLACK, LEON
T-10094
EFTA01114690
LEON D. & DEBRA BLACK
Form 8858 (Rev. 12-2013)
Schedule G I Other Information (continued)
Page 3
5a Was any portion of the dual consolidated loss in question 4 taken into account in computing consolidated taxable income for the
year? If "Yes; go to 5b. 'No; skip 5b and 5c
b Was this permitted domestic use of the dual consolidated loss under Reg. 1.1503(d)-6? If 'Yes, see instructions and skip 5c.
It"No," go to 5c
c If this was not a permitted domestic use, was the dual consolidated loss used to compute consolidated taxable income as provided
under Reg. 1.503(d)-4?
If "Yes; enter the separate unit's contribution to the cumulative consolidated Taxable income (cumulative register) as of the
beginning of the lax year Ne. $
See Instructions.
6 During the tax year, did the foreign disregarded entity pay or accrue any foreign tax that was disqualified for credit under
section 901(m)?
7 During the tax year, did the foreign disregarded entity pay or accrue foreign taxes to which section 909 applies, or treat foreign
taxes that were previously suspended under section 909 as no longer suspended?
8 Answer the following question only if the tag owner of the foreign disregarded entity k a controlled foreign corporation
(CFC): Were there any intracompany transactions between the foreign disregarded entity and the CFC or any other branch of the
CFC during the tax year, in which the foreign disregarded entity acted as a manufacturing, selling, or purchasing branch?
Current Earnings and Profits or Taxable Income (see instructions)
Schedule H
Important Enter the amounts on lines 7 through 6 in functional currency.
I
Current year net income or (loss) per foreign books of account
2 Total net additions
3 Total net subtractions
4 Current earnings and profits (or taxable income — see instructions) (Iine 1 plus ire 2
us line 3)
5
DASTM gain or loss (if applicable)
6 Combine lines 4 and 5
7 Current earnings and profits (or taxable income) in U.S. doNars eine 6 translated at the average exchange rate determined under
section 989(b) and the related regulations (see instructions))
Enter exchange rate used for line 7 ►
Yes
No
40;7
1
2
3
4
5
6
7
Form 8858 (Rev. 12-2013)
31,413
V-10.13
535
13061007 133415 T-1009
2013.04030 BLACK, LEON
T-10094
EFTA01114691
Form 8858
Information Return of U.S. Persons With Respect To Foreign Disregarded Entities
IP. Information about Form 8858 and its separate instructions Is at vAvw.Irs.gov/fortn885&
OMB No. 1545-1910
0%9. December 2013)
Deportment of the Tit-awry
Internal Revenue Service
Name of person filing this return
LEON D. & DEBRA BLACK
Information furnished for the foreign disregarded entitys annual accounting period (see instructions)
Atlachinent
beginning JAN 1
.2013
and ending DEC 31
.
$80taencer No 140
2013
Flier's Identifying number
Number. street. and room or suite no. (or P.O. box number it mail is not delivered to street address)
City or
state. and ZIP code
,
Filer's tax year beginning
JAN 1
, 20 13 , and ending
DEC 31
,2013
Important Fill in all applicable lines and schedules. AD information must be in English. All amounts must be stated in U.S. dollars unless otherwise indicated.
1a Name and address of foreign disregarded entity
PHAIDON PRESS SOCIETE A RESPONS LIM
55 RUE TRAVERSIERE
PARIS
FRANCE
Country(ies) under whose laws organized and entity type under local tax law
FRANCE
CORPORATION
FRANCE
CORPORATION
f If benefits under a U.S. tax treaty were claimed with respect to income
of the foreign disregarded entity, enter the treaty and article number
75012
6(1) U.S. identifying number, if any
b(2) Reference ID number (see instructions)
g Country in which principal
business activity is conducted
FRANCE
2
Provide the following information for the foreign disregarded entity's a counting period stated above.
a Name, address, and identifying number of branch office or agent (if any) in the
United States
Gar
d Date(s) of organization
10 03 12
10 03 12
b Principal business
activity
PUBLISHING
e Effective date as foreign
disregarded entity
10/03/12
I Functional currency
EUROPEAN
UNION, EURO
b NAT,. and arktm:11ncAkarto CCAPCIAIG dep.rtrnent. It agoacal590 01 CerS0001wIth 0.44100,
44 tne books and !awes of the foremen oegagarded entity. AM the IOCat1011 ol such books
and reeves. it caf9rent
ANDREW PRICE
REGENTS WHARF, ALL SAINTS ST
LONDON,
N1 9PA
UNITED KINGDOM
3
For the tax owner of the foreign disregarded entity (if different from the filer) provide the following:
a Name and address
b Annual accounting period covered by the return (see instructions)
c(1) U.S. identifying number, if any
c(2) Reference ID number (see instructio s)
d Country under whose laws organized
e Functional currency
4 For the direct owner of the foreign disregarded entity (if different from the tax owner provide the following:
a Name and address
PHAIDON PRESS LTD
b Country under whose laws organized
REGENTS WHARF,
LONDON,
N1
ALL
9PA
SAINTS ST
UNITED KINGDOM
UNITED KINGDOM
c U.S. identifying number, if any
currency
141Functional
ITED KINGDOM,PO
5
Attach en organizational chart that identities the name. placement percentageof central*. tax classilication. and county of organization of all entities in the chain of ownership between the tax
cr.mar and the foreign disregarded entity. and the chain of erne/ship between the loralr disregarded entity end each entity In which the40441r disregarded entity has a 1094 or more direct or
ndieci interest. See instructions.
SEE STATEMENT 83
For Paperwork Reduction Act Notice, see the separate instructions.
kOill 8858 (Rev. 12-2013)
512411 12-10.15 IHA
13061007 133415 T-1009
536
2013.04030 BLACK, LEON
T-10094
EFTA01114692
LEON D. & DEBRA BLACK
Form 8858 (Rev. 12-2013)
Page 2
Schedule C I Income Statement (see instructions)
Important Report all information in functional currency in accordance with U.S. GAAP. Also, report each amou
—nitn U.S. dollars transla
functional
currency (using GAAP translation rules or the average exchange rate determined under section 989(b)). If the functional currency is the U.S. dollar.
complete only the U.S. Dollars column. See instructions for special rules for foreign disregarded entities that use DASTM.
If you are using the average exchange rate (determined under section 989(b)), check the following box
D6
1 Gross receipts or sales (net of returns and allowances)
2 Cost of goods sold
3 Gross profit (subtract line 2 from line 1)
4 Other income
5
Total income (add Ines 3 and 4)
6 Total deductions
7
Other adjustments
8
Net income (loss) per books
Functional Currency
U.S. Dollars
1
2
3
4
5
6
652,825.
7
8
-652,825.
I-Schedule C-1 J Section 987 Gain or Loss Information
(a)
(b)
Note. See the instructions if there are multiple recipients of remittances
Amount stated in
Amount stated in
from the foreign disregarded entity.
functional currency of
functional currency
foreign disregarded entity
of recipient
1 Remittances from the foreign disregarded entity
1
2 Section 987 gain (loss) of recipient
2
Yes
No
3 Were all remittances from the foreign disregarded entity treated as made to the direct owner?
4 Did the tax owner change its method of accounting for section 987 gain or loss with respect to remittances from the foreign disregarded
entity during the tax year?
..
Schedule F I Balance Sheet
Important Report all amounts in U.S. dollars computed in functional currency and translated into U.S. dollars in accordance with U.S. GAAP.
See instructions loran exception for foreign disregarded entities that use DASTM.
Assets
2 Other
and other current
r assets
3 Total assets
r
L
ai
1 Cash
assets
4 Liabilities
5 Owner's equity
6 Total liabilities and owner's equity
Schedule G I Other Information
Liabilities and OvOlity
%
• in
Beginning of annual
accounting period
End of annual
accounting period
1
2
3
351,461.
262,129.
2,058,576.
2,410,037.
1,830,361.
2,092,490.
4
5
6
2,547,870.
2,854,751.
137,833.
-762,261.
2,685,703.
2,092,490.
1 During the tax year, did the foreign disregarded entity own an interest in any trust?
2 During the tax year, did the foreign disregarded entity own at least a 10% interest, directly or indirectly, in any foreign partnership?
3 Answer the following question only if the foreign disregarded entity made its Section to be treated as disregarded from
its owner during the tax year: Did the tax owner claim a loss with respect to stock or debt of the foreign disregarded entity as a
result of the election?
4 If the interest in the foreign disregarded entity is a separate unit under Reg. 1.1503(d)-1(bX4) or part of a combined separate unit
under reg. 1.1503(d)-1(bX4)(ii) does the separate unit or combined separate unit have a dual consoidated loss as defined in Reg.
1.1503(d)-1(b)(5)(10?
If "Yes; enter the amount of the dual consolidated loss► $
Answer question 5a.
Yes
No
X
X
N /A
Form 8858 (Rev. 12-2013)
31,412
12-10.13
537
13061007 133415 T-1009
2013.04030 BLACK, LEON
T-10094
EFTA01114693
LEON D. & DEBRA BLACK
Form 8858 (Rev. 12-2013)
Schedule G I Other Information (continued)
Page 3
5a Was any portion of the dual consolidated loss in question 4 taken into account in computing consolidated taxable income for the
year? If "Yes; go to 5b. 'No; skip 5b and 5c
b Was this permitted domestic use of the dual consolidated loss under Reg. 1.1503(d)-6? If 'Yes, see instructions and skip 5c.
It"No," go to 5c
c If this was not a permitted domestic use, was the dual consolidated loss used to compute consolidated taxable income as provided
under Reg. 1.503(d)-4?
If "Yes; enter the separate unit's contribution to the cumulative consolidated Taxable income (cumulative register) as of the
beginning of the lax year Ne. $
See Instructions.
6 During the tax year, did the foreign disregarded entity pay or accrue any foreign tax that was disqualified for credit under
section 901(m)?
7 During the tax year, did the foreign disregarded entity pay or accrue foreign taxes to which section 909 applies, or treat foreign
taxes that were previously suspended under section 909 as no longer suspended?
8 Answer the following question only if the tag owner of the foreign disregarded entity k a controlled foreign corporation
(CFC): Were there any intracompany transactions between the foreign disregarded entity and the CFC or any other branch of the
CFC during the tax year, in which the foreign disregarded entity acted as a manufacturing, selling, or purchasing branch?
Current Earnings and Profits or Taxable Income (see instructions)
Schedule H
Important Enter the amounts on lines 7 through 6 in functional currency.
I
Current year net income or (loss) per foreign books of account
2 Total net additions
3 Total net subtractions
4 Current earnings and profits (or taxable income — see instructions) (Iine 1 plus ire 2
us line 3)
5
DASTM gain or loss (if applicable)
6 Combine lines 4 and 5
7 Current earnings and profits (or taxable income) in U.S. doNars eine 6 translated at the average exchange rate determined under
section 989(b) and the related regulations (see instructions))
Enter exchange rate used for line 7 ►
Yes
No
40;7
1
2
3
4
5
6
7
Form 8858 (Rev. 12-2013)
31,413
V-10.13
538
13061007 133415 T-1009
2013.04030 BLACK, LEON
T-10094
EFTA01114694
Form 8858
►
Information Return of U.S. Persons With Respect To Foreign Disregarded Entities
Information about Form 8858 and its separate instructions Is at vAvw.lrs.gov/form885&
OMB No. 1545-1910
December 2013)
Department of the Treasury
Intrrnal Revenue Service
Name of person filing this return
LEON D. & DEBRA BLACK
Information furnished for the foreign disregarded entitys annual accounting period (see instructions)
AtIrchinent
beginning JAN 1
.2013
. and ending DEC 31
.20 13
Dacitaence No 140
Flier's Identifying number
Number, street, and room or suite no. (or P.O. box number it mail is not delivered to street address)
City or
state. and ZIP code
,
Filer's tax year beginning
JAN 1
, 20 13 , and ending
DEC 31
,2013
Important Fill in all applicable lines and schedules. AD information must be in English. All amounts must be stated in U.S. dollars unless otherwise indicated.
la Name and address of foreign disregarded entity
PHAIDON PRESS LTD
REGENTS WHARF, ALL SAINTS ST
LONDON
UNITED KINGDOM
e Country(ies) under whose laws organized and entity type under local tax law
UNITED KINGDOM
CORPORATION
N1 9PA
6(1) U.S. identifying number, if any
b(2) Reference ID number (see instructions)
d Date(s) of organization
09 28 12
e Effective date as foreign
disregarded entity
10/03/12
I Functional currency
If benefits under a U.S. tax treaty were claimed with respect to income I g Country in which principal
of the foreign disregarded entity, enter the treaty and article number
business activity is conducted
ITED KINGDOM
b Principal business
activity
PUBLISHING
UNITED
KINGDOM, POUND
2
Provide the following information for the foreign disregarded entity's a counting period stated above.
a Name, address, and identifying number of branch office or agent (if any) in the
b Name and addrm; fincAnIng co r pecatO (10pM1Mant. It applicable) of person(5)with custody
United States
of tne books and !encode of the foregn odiegarded entity. AM the
01 such Wks
--<
\
and records. it decrent
ANDREW PRICE
REGENTS WHARF, ALL SAINTS ST
LONDON,
N1 9PA
UNITED KINGDOM
3
For the tax owner of the foreign disregarded entity (if different from the filer) provide the following:
a Name and address
b Annual accounting period covered by the return (see instructions)
c(1) U.S. identifying number, if any
e(2) Reference ID number (see instructio s)
d Country under whose laws organized
e Functional currency
4
For the direct owner of the foreign disregarded entity (if different from the tax owner provide the following:
a Name and address
ii Country under whose laws organized
JMWT LIMITED
REGENTS WHARF, ALL SAINTS ST
UNITED KINGDOM
LONDON,
N1 9PA
1 1
UNITED KINGDOM
e U.S. identifying number, if any
d Functional currency
ITED KINGDOM,PO
Attach en crgenizational chart that identities the none. placement percentage of ownaship. tax classilicatien. and county of crcpnization of all entities in the chain of ownership between the tax
(ha and the loreign disregarded entity. and the chore 01 Game/ship between the loreir disregarded entity end each entity In which the foreign disregarded entity Meath% or more direct or
ndieci interest. See instructions.
SEE STATEMENT 84
For Paperwork Reduction Act Notice, see the separate instructions.
k0ill 8858 (Rev. 12-2013)
5
512411 12-10.15 IHA
13061007 133415 T-1009
539
2013.04030
BLACK, LEON
T-10094
EFTA01114695
LEON D. & DEBRA BLACK
Form 8858 (Rev. 12-2013)
Page 2
ScheduleS4 Income Statement (see instructions)
Important Repon a I information in functional currency in accordance with U.S. GAAP. Also, report each amou
—nttn U.S. dollars transla
functional
currency (using GAAP translation rules or the average exchange rate determined under section 989(b)). If the functional currency is the U.S. dollar.
complete only the U.S. Dollars column. See instructions for special rubs for foreign disregarded entities that use DASTM.
If you are using the average exchange rate (determined under section 989(b)), check the following box
D6
Functional Currency
U.S. Dollars
1 Gross receipts or sales (net of returns and allowances)
1
33,361,248.
2 Cost of goods sold
2
15,349,200.
3 Gross profit (subtract line 2 from line 1)
3
18,012,048.
4 Other income
4
319,082.
5
Total income (add Ines 3 and 4)
5
18,331,130.
6 Total deductions
6
19,922,091.
7
Other adjustments
7
8
Net income (loss) per books
8
-1,590,961.
I-Schedule C-1 J Section 987 Gain or Loss Information
(a)
(b)
Note. See the instructions if there are multiple recipients of remittances
from the foreign disregarded entity.
Amount stated in
functional currency of
foreign disregarded entity
Amount stated in
functional currency
of recipient
1 Remittances from the foreign disregarded entity
2 Section 987 gain (loss) of recipient
2
Yes
No
3 Were all remittances from the foreign disregarded entity treated as made to the direct owner?
4 Did the tax owner change its method of accounting for section 987 gain or loss with respect to remittances from the foreign disregarded
entity during the tax year?
...
Schedule F I Balance Sheet
Important Report all amounts in U.S. dollars computed in functional currency and translated into U.S. dollars in accordance with U.S. GAAP.
See instructions loran exception for foreign disregarded entities that use DASTM.
Assets
1 Cash and other current assets
2 Other assets
e
Liabilities and Car:n
fifty
%C
O
3 Total assets
4 Liabilities
5 Owner's equity
6 Total liabilities and owner's equity
Schedule G I Other Information
L
Beginning of annual
accounting period
End of nnual
accounting period
1,028,518.
1
2
3
29,816,548.
29,816,548.
33,227,719.
34,256,237.
4
5
6
15,409,988.
14,406,560.
29,816,548.
17,725,782.
16,530,455.
34,256,237.
1 During the tax year, did the foreign disregarded entity own an interest in any trust?
2 During the tax year, did the foreign disregarded entity own at least a 10% interest, directly or indirectly, in any foreign partnership?
3 Answer the following question only if the foreign disregarded entity made its election to be treated as disregarded from
Its owner during the tax year: Did the tax owner claim a loss with respect to stock or debt of the foreign disregarded entity as a
result of the election?
4 If the interest in the foreign disregarded entity is a separate unit under Reg. 1.1503(d)-1(bX4) or part of a combined separate unit
under reg. 1.1503(d)-1(bX4)(ii) does the separate unit or combined separate unit have a dual consoidated loss as defined in Reg.
1.1503(d)-1(b)(5)(10?
If "Yes; enter the amount of the dual consolidated loss► $
Answer question 5a.
Yes
No
X
X
X
N /A
Form 8858 (Rev. 12-2013)
31,412
12-10.13
540
13061007 133415 T-1009
2013.04030 BLACK, LEON
T-10094
EFTA01114696
LEON D. & DEBRA BLACK
Form 8858 (Rev. 12-2013)
Schedule G I Other Information (continued)
Page 3
5a Was any portion of the dual consolidated loss in question 4 taken into account in computing consolidated taxable income for the
year? If "Yes; go to 5b. 'No; skip 5b and 5c
b Was this permitted domestic use of the dual consolidated loss under Reg. 1.1503(d)-6? If 'Yes, see instructions and skip 5c.
It"No," go to 5c
c If this was not a permitted domestic use, was the dual consolidated loss used to compute consolidated taxable income as provided
under Reg. 1.503(d)-4?
If "Yes; enter the separate unit's contribution to the cumulative consolidated Taxable income (cumulative register) as of the
beginning of the lax year Ne. $
See Instructions.
6 During the tax year, did the foreign disregarded entity pay or accrue any foreign tax that was disqualified for credit under
section 901(m)?
7 During the tax year, did the foreign disregarded entity pay or accrue foreign taxes to which section 909 applies, or treat foreign
taxes that were previously suspended under section 909 as no longer suspended?
8 Answer the following question only if the tag owner of the foreign disregarded entity k a controlled foreign corporation
(CFC): Were there any intracompany transactions between the foreign disregarded entity and the CFC or any other branch of the
CFC during the tax year, in which the foreign disregarded entity acted as a manufacturing, selling, or purchasing branch?
Current Earnings and Profits or Taxable Income (see instructions)
Schedule H
Important Enter the amounts on lines 7 through 6 in functional currency.
I
Current year net income or (loss) per foreign books of account
2 Total net additions
3 Total net subtractions
4 Current earnings and profits (or taxable income — see instructions) (Iine 1 plus ire 2
us line 3)
5
DASTM gain or loss (if applicable)
6 Combine lines 4 and 5
7 Current earnings and profits (or taxable income) in U.S. doNars eine 6 translated at the average exchange rate determined under
section 989(b) and the related regulations (see instructions))
Enter exchange rate used for line 7 ►
Yes
No
40;7
1
2
3
4
5
6
7
Form 8858 (Rev. 12-2013)
31,413
V-10.13
541
13061007 133415 T-1009
2013.04030 BLACK, LEON
T-10094
EFTA01114697
Form 8858
Information Return of U.S. Persons With Respect To Foreign Disregarded Entities
IP. Information about Form 8858 and its separate instructions Is at vAvw.irs.gov/forn1885&
OMS No. 1545-1910
Om. December 2013)
Oeportment of the Treasury
Minimal Revenue Service
Name of person filing this return
LEON D. & DEBRA BLACK
Information furnished for the foreign disregarded entitys annual accounting period (see instructions)
Attachment
beginning JAN 1
.2013
. and ending DEC 31
.
Salome* No 140
2013
Filer's identifying number
Number. street. and room or suite no. (or P.O. box number if mail is not delivered to street address)
City or
state. and ZIP code
,
Filer's tax year beginning
JAN 1
, 20 13 , and ending
DEC 31
,2013
Important Fill in all applicable lines and schedules. AD information must be in English. All amounts must be stated in US. dollars unless otherwise indicated.
fa Name and address of foreign disregarded entity
JMWT ACQUSITION LIMITED PARTNERSHIP
REGENTS WHARF, ALL SAINTS ST
LONDON
N1 9PA
UNITED KINGDOM
b(1) U.S. identifying number, if any
98-1081299
b(2) Reference ID number (see instructions)
e Country(ies) under whose laws organized and entity type under local tax law
UNITED KINGDOM
UK PARTNERSHIP
d Date(s) of organization
09 28 12
e Effective date as foreign
cfisregarded entity
If benefits under a U.S. tax treaty were claimed with respect to income
of the foreign disregarded entity, enter the treaty and article number
g Country in which principal
business activity is conducted
b Principal business
activity
I
Functional currency
UNITED
KINGDOM, POUND
2
Provide the following information for the foreign disregarded entity's a counting period stated above.
a Name, address, and identifying number of branch office or agent (if any) in the
b NAT,. and adctmstlecnating corporate dap.mreent. It applicatain 01 P.SOIXO with mated/
ea the
and IBCOICA of the forage Owegarded entity, and the location of such bock;
United States
and records. it dement
3
For the tax owner of the foreign disregarded entity (if different from the filer) provide the following:
a Name and address
b Annual accounting period covered by the return (see instructions)
e(1) U.S. identifying number, if any
e(2) Reference ID number (see instructio s)
d Country under whose laws organized
e Functional currency
4
For the direct owner of the foreign disregarded entity (if different from the tax owner provide the following:
a Name and address
b Country under whose laws organized
e U.S. identifying number, if any
d Functional currency
5
Attach an mganizatianal chart that identities the name. placement. percentage of ownership. tax dassilication. gridcounty of organization of all entities in the chain of ownership between the tax
ma and the loreign disregarded entity. and the chain of ownership between the Inimical disregarded entity end each entity In which theWeir disregarded entity has a ID% or more direct or
edict interest. See. instructions.
SEE STATEMENT 85
For Paperwork Reduction Act Notice, see the separate instructions.
F -in 8858 (Rev. 12-2013)
512411 12-10.15 IHA
13061007 133415 T-1009
542
2013.04030 BLACK, LEON
T-10094
EFTA01114698
LEON D. & DEBRA BLACK
Form 8858 (Rev. 12-2013)
Page 2
ScheduleS4 Income Statement (see instructions)
Important Repon a I information in functional currency in accordance with U.S. GAAP. Also, report each amou
—nitn U.S. dollars transla
functional
currency (using GAAP translation rules or the average exchange rate determined under section 989(b)). If the functional currency is the U.S. dollar.
complete only the U.S. Dollars column. See instructions for special rubs for foreign disregarded entities that use DASTM.
If you are using the average exchange rate (determined under section 989(b)), check the following box
D6
Functional Currency
U.S. Dollars
1 Gross receipts or sales (net of returns and allowances)
1
2 Cost of goods sold
2
3 Gross profit (subtract line 2 from line 1)
3
4 Other income
4
5
Total income (add Ines 3 and 4)
5
6 Total deductions
6
7
Other adjustments
7
8
Net income (loss) per books
8
I-Schedule C-1 I Section 987 Gain or Loss Information
la)
(b)
Note. See the instructions if there are multiple recipients of remittances
from the foreign disregarded entity.
Amount stated in
functional currency of
foreign disregarded entity
Amount stated in
functional currency
of recipient
1 Remittances from the foreign disregarded entity
1
2 Section 987 gain (loss) of recipient
2
Yes
No
3 Were all remittances from the foreign disregarded entity treated as made to the direct owner?
4 Did the tax owner change its method of accounting for section 987 gain or loss with respect to remittances from the foreign disregarded
entity during the tax year?
..
Schedule F I Balance Sheet
Important Report all amounts in U.S. dollars computed in functional currency and translated into U.S. dollars in accordance with U.S. GAAP.
See instructions loran exception for foreign disregarded entities that use DASTM.
Assets
1 Cash and other current assets
2 Other assets
3 Total assets
4 Liabilities
5 Owners equity
6 Total liabilities and owner's equity
Schedule G I Other Information
Beginning of annual
accounting period
(
End of annual
accounting period
1
2
3
67,332,371.
67,332,371.
70,831,736.
70,831,736.
4
5
6
67,332,371.
67,332,371.
70,831,736.
70,831,736.
1 During the tax year, did the foreign disregarded entity own an interest in any trust?
2 During the tax year, did the foreign disregarded entity own at least a 10% interest, directly or indirectly, in any foreign partnership?
3 Answer the following question only if the foreign disregarded entity made its election to be treated as disregarded from
Its owner during the tax year: Did the tax owner claim a loss with respect to stock or debt of the foreign disregarded entity as a
result of the election?
4 If the interest in the foreign disregarded entity is a separate unit under Reg. 1.1503(d)-1(bX4) or part of a combined separate unit
under reg. 1.1503(d)-1(bX4)(ii) does the separate unit or combined separate unit have a dual consoidated loss as defined in Reg.
1.1503(d)-1(b)(5)(10?
If 'Yes; enter the amount of the dual consolidated
$
Answer question 5a.
Form 8858 (Rev. 12-2013)
Yes
No
X
X
N /A
31,412
12-10.13
543
13061007 133415 T-1009
2013.04030 BLACK, LEON
T-10094
EFTA01114699
LEON D. & DEBRA BLACK
Form 8858 (Rev. 12-2013)
Schedule G I Other Information (continued)
5a Was any portion of the dual consolidated loss in question 4 taken into account in computing consolidated taxable income for the
year? If "Yes; go to 5b. 'No; skip 5b and 5c
b Was this permitted domestic use of the dual consolidated loss under Reg. 1.1503(d)-6? If 'Yes, see instructions and skip 5c.
It"No," go to 5c
c If this was not a permitted domestic use, was the dual consolidated loss used to compute consolidated taxable income as provided
under Reg. 1.503(d)-4?
If "Yes; enter the separate unit's contribution to the cumulative consolidated Taxable income (cumulative register) as of the
beginning of the lax year Ne. $
See Instructions.
6 During the tax year, did the foreign disregarded entity pay or accrue any foreign tax that was disqualified for credit under
section 901(m)?
7 During the tax year, did the foreign disregarded entity pay or accrue foreign taxes to which section 909 applies, or treat foreign
taxes that were previously suspended under section 909 as no longer suspended?
8 Answer the following question only if the tag owner of the foreign disregarded entity k a contioNed foreign corporation
(CFC): Were there any intracompany transactions between the foreign disregarded entity and the CFC or any other branch of the
CFC during the tax year, in which the foreign disregarded entity acted as a manufacturing, selling, or purchasing branch?
Schedule H I Current Earnings and Profits or Taxable Income (see instructions)
Important Enter the amounts on lines 7 through 6 in functional currency.
I
Current year net income or (loss) per foreign books of account
2 Total net additions
3 Total net subtractions
4 Current earnings and profits (or taxable income — see instructions) (Iine 1 plus ire 2
us line 3)
5
DASTM gain or loss (if applicable)
6 Combine lines 4 and 5
7 Current earnings and profits (or taxable income) in U.S. doNars eine 6 translated at the average exchange rate determined under
section 989(b) and the related regulations (see instructions))
Enter exchange rate used for line 7 ►
Yes
Pane 3
No
X
X
40;7
1
2
3
4
5
6
7
Form 8858 (Rev. 12-2013)
31,413
V-10.13
544
13061007 133415 T-1009
2013.04030 BLACK, LEON
T-10094
EFTA01114700
Technical Artifacts (6)
View in Artifacts BrowserEmail addresses, URLs, phone numbers, and other technical indicators extracted from this document.
Domain
vavw.irs.govDomain
vavw.lrs.govPhone
13061007Phone
1545-1910Phone
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